Dirk Kempthorne
Secretary of the Interior
Dear Secretary Dirk Kempthorne:
My
name is Bill Kennedy, and I traveled here today from
The ranch that I operate is one of 1,400 family
farms and ranches that depend on water supplies from the Klamath Irrigation
Project (“Project”). My ranch has been a private wildlife refuge for over 25
years. In 2001 single species management as interpreted by the ESA allocated
1000 acres of my irrigated wildlife habitat for meeting two unattainable
biological opinions. Over 400 species of vertebrates lost food and habitat to
benefit two species on the endangered species list.
The members of the Family Farm Alliance have many other examples of how onerous
and expensive processes associated with the U.S. Department of Interior can be.
Many collaborative projects in Western states are delayed or stopped by the sole
association with Interior. We also have many examples of how relationships with
Interior can work.
Today, my focus is on my back yard, the
Building
Relationships
In order for Interior to foster meaningful, working relationships it must take
action today to gain respect and trust. For the past twenty years, private
landowners have become reluctant to associate with many of Interiors
departments. The normal relationship has been one of Interior mandating to the
landowner what must be done. There typically is more interest by your
departments in the regulations that restrict Interiors’ actions than on ways
to create flexibility.
There are examples of positive and meaningful holistic resource management as
well. The relationship between the wildlife refuge management and the food
producing family farmers is better today than it was just six years ago.
Willingness to create flexibility by people like Ron Cole and David Mauser has
resulted in a successful Walking Wetlands program. This is a partnership program
that works.
I do complement the Klamath ERO office of Fish and Wildlife as well as the
Klamath Reclamation project office for developing better working relationship
this last year. This has resulted in a flexible implementation of the Biological
Opinion for Suckers and Coho. Unfortunately this seems to be headed to the court
system.
At upper ends of the Klamath basin we see Interior to continue in its land
acquisition goals. This direction is contrary to constructive conservation. Over
the past 25 years, close to 30,000 acres of productive private irrigated ground
has been acquired by Interior. Besides reducing our county tax base, the result
has been to dismantle a very important infrastructure for interstate and
international commerce.
The irrigated pasture of the upper marsh and ranches like Wood River Ranch,
Agency Lake Ranch and now The Barnes Ranch has been some of the most productive
pasture in the world. Cattle producers depend on pasture in the Klamath basin to
complement winter-feeding cycles in northern
We have meaningful collaboration by some Fish and Wildlife managers. But,
Interior is also playing a destructive role in the dismantling of our natural
resource production. From the purchase of Wood River Ranch by BLM to
Reclamations acquisition of Agency Lake Ranch, the agricultural community has
been told that the transferred ownership and management will result in water
supply certainty. Instead we have more stringent Biological Opinions that are
interpreted to reduce our water supply flexibility.
Today, Interior should not be surprised that there is little support for the
acquisition of The Barnes Ranch. We do not believe claims that it will be
managed for water supply certainty. The only certainty that this direction has
given us is certainly less irrigated production for our local and national
economy.
The one direction that Interior could take to build its relationships with
private land managers is to get out of the land acquisition business. The
federal government needs to reduce its land holdings. Instead of buying up
private productive irrigated pasture in the Klamath basin, Interior should lead
the federal family towards land dispersal. Promote constructive conservation
with neighbors by developing trust. Develop trust by getting off the land
acquisition track. There are many examples set by the Bureau of Reclamation on
how transfer of project ownership has benefited Interior, the stakeholders and
the environment. Project transfer continues to be an advocacy of The Family Farm
Alliance.
Looking to the forests of our watershed opens the eyes. Private lands like those
managed by the Thomas Shaw family produce a sustainable harvest with little
danger of catastrophic forest fires. Yet these same lands are surrounded by
national forest that has no management, no harvest and fuel loads waiting to
burn the earth beyond recognition and destroy what the Shaw family has managed
for excellence. Like many of the departments of Interior, the U.S. Forest
Service has been castrated by inflexible implementation of NEPA, ESA and CWA.
The forest can be managed as a holistic resource when it is owned by our state
or a private land manager like the Shaw family.
The short term and immediate direction for Interior to follow is in regards to
interpretation and implementation of the ESA. There can be flexible and
responsible use of the ESA. This includes requiring current and new listings to
have a recovery plan. Plans should be reviewed every five years. There should be
measurable goals and objectives. The primary objective should be to de-list a
species.
Science used for listing and delisting a species should not just be the “best
available”, it should stand up to peer review.
Nowhere are cooperative relationships more important than in regard to NEPA.
Administrative action to make the ESA a successful tool needs to address NEPA as
well. All of the suggestions listed below become workable when landowners are
included as applicants in the process.
1. NEPA analyses should require that value be assigned to continued agricultural
production in a project area.
2. Impacts of drought and continuing water demands must be assessed and built
into the NEPA process.
3. Anything that can be done to streamline the overall permitting process (NEPA,
ESA, Clean Water Act, etc.) should be encouraged.
4. Agency work on biological opinions should be required to keep pace with
development of NEPA compliance documents.
5. Congress should consider legislation that would allow the state’s
legislative and planning process to be considered in establishing purpose and
need for construction of dam and reservoir projects.
6. Developing a reasonable range of alternatives is also very important in
project planning and the NEPA process. Alternatives must meet the need and
purpose for the project and must be capable of being implemented. It is
important to use the NEPA process to help determine the most appropriate
alternative from the set of reasonable alternatives.
7. Cooperative efforts are important for moving projects through the NEPA and
permitting processes. State and local sponsors should become cooperating
agencies in the NEPA process if possible and if not, should be allowed to serve
on the project EIS interdisciplinary team.
Planning for the future
Today we see changes in our lives dramatically affect what we live for. Today we
grow crops to produce power as well as food and fiber.
Interior must recognize the slippery path that we are in danger of going down in
relation to our national security. We cannot afford to risk our secure ability
to produce our own food and fiber and power.
In the Klamath basin issue we have had tremendous participation in discussions
revolving around FERC licensing of hydroelectricity. With the leadership of
people like
Dismantling our power capacity on the
I believe we can have modern hydropower with effective fish passage and modern
hatchery management. We can have vibrant fisheries up and down the Pacific
coast. Renewable power can complement this.
A few people in our nation are willing to see our roads; schools, reservoirs and
our power production crumble from lack of maintenance and lack of planning for
the future. In the case of the four big dams on the
At the fourth World Water Forum in
"Investment in hydroelectric infrastructure is not a choice anymore for
Africa, it is a must," Jamal Shagir, the World Bank's director of water and
energy, said in a report
While we are talking about removing hydroelectric capacity that is directly
linked to the development of our irrigated crop production, the World Bank
recognizes the importance of hydroelectricity to bring people out of poverty and
away from dependence on other nations.
While we continue to see our infrastructure of irrigated agriculture ignored and
dismantled, third world nations in Africa, the
Are we willing to move towards an insecure poverty or do we value the importance
of hydroelectricy? Do we want to import our food fiber and power or do we
believe in the security of domestic capacity and capability?
Interior has an important direction to take in the next few years. Experience of
people like those of you at this listening session is about to retire. As the
land mangers who have built collaboration go fishing, Interior hires more
biologists and GIS specialists that do not have a clue where the water will flow
after 5:00 PM on Friday afternoon.
Interior needs to replace those that innovate and care for the relationships
created today with individuals capable and dedicated to our nation’s needs.
This is a difficult task before you.
I use to have four or five high school students ask for summer jobs on my ranch.
Today, I compete with the house construction business for reliable Hispanic
workers. The president of The Family Farm Alliance, Pat O’Toole, hires
shepherds from
Interior has played a vital role in the development of the West. That
development goes on today at an unprecedented rate, and is placing significant
pressure on all our resources. We are better off with our cooperative
conservation and the incentives we present each other throughout the west.
The Family Farm Alliance will continue to advocate for taking care of the
infrastructure and resource development that includes new water supplies and
healthy wildlife habitat. We look forward to our improving relations the United
States Department of Interior.
Thank you for your time and attention.
William D. Kennedy
Chairman of the Board
The Family Farm